FCC Progress Report III February 15, 2019 Federal Communications Commission Experimental Licensing Branch MS 1300E1 445 12th Street SW Washington, DC 20554 Table of Contents I. Introduction …………………………………………………………………… page 2 II. Company Background & Technological Approach ………………………. page 3 a. Field Tests & Results III. Starry’s Network Deployment ………………………………………………… page 9 a. Network Deployment: Opportunities & Obstacles b. Market Status c. MDU Market: Challenges and Opportunities IV. Starry Connect: Addressing the Digital Divide …………………………….. page 17 V. Looking Ahead: 2019 & 2020 ……………………………………………….. page 18 VI. Conclusion ……………………………………………………………………… page 19 1 I. Introduction In December 2017, Starry, Inc. (“Starry”) filed its second Progress Report with the Federal Communications Commission (“FCC” or “Commission”) updating the Commission on Starry’s progress in developing, deploying and testing its fixed 5G wireless broadband access network. This third Progress Report contains additional updated information related to Starry’s deployment efforts in the markets in which it holds experimental test authority licenses. Today, more than 24 million Americans lack access to a high-speed internet broadband connection and among lower-income Americans, nearly half do not have an internet connection at home.1 The benefits of broadband access in the home are well-known: increased job and educational opportunities, increased access to healthcare and expansion of broader economic opportunities for whole communities.2 Ubiquitous, reliable internet is a critical part of our nation’s infrastructure and a key driver of economic growth. The Commission, recognizing that reliable and affordable broadband is critical to communities both large and small, has undertaken several rulemakings that address barriers to broadband expansion and has already begun to implement policies designed to encourage deployment of new access networks and spur broadband adoption across diverse geographies and demographics.3 From adoption of diverse and flexible spectrum access policies to easing deployment barriers, the Commission via its 5G FAST initiative is providing new entrants – 1 Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a Reasonable and Timely Fashion, GN Docket No. 17-199, 2018 Broadband Deployment Report, 33 FCC Rcd 1660 (2018) (2018 Broadband Deployment Report); Monica Anderson, Digital Divide Persists Even as Lower-Income Americans Make Gains in Tech Adoption, PEW RESEARCH CENTER (Mar. 22, 2017); http://www.pewresearch.org/fact- tank/2017/03/22/digital-divide-persists-even-as-lower-income-americans-make-gains-in-tech-adoption/. 2 See U.S. Counsel of Economic Advisers Issue Brief, The Digital Divide and Economic Benefits of Broadband Access (Mar. 2016), https://obamawhitehouse.archives.gov/sites/default/files/page/files/20160308_broadband_cea_ issue_brief.pdf ; Intel World Ahead, Realizing the Benefits of Broadband (2010), https://www.intel.com/content/ dam/www/public/us/en/documents/white-papers/world-ahead-broadband-paper.pdf. 3 Use of Spectrum Bands Above 24 GHz For Mobile Radio Services; Amendment of Parts 1, 22, 24, 27, 74, 80, 90, 95, and 101 To Establish Uniform License Renewal, Discontinuance of Operation, and Geographic Partitioning and Spectrum Disaggregation Rules and Policies for Certain Wireless Radio Services, Third Report and Order, Memorandum Opinion and Order, and Third Further Notice of Proposed Rulemaking, GN Docket No. 14-177, 33 FCC Rcd 5576 (2018); Accelerating Wireless Broadband Deployment by Removing Barriers to Infrastructure Investment, WT Docket 17-79, Second Report and Order, FCC 18-30 (rel. Mar. 22, 2018). 2 utilizing innovative new technologies like Starry’s – the opportunity to successfully compete with well-entrenched incumbents. Emerging “5G” technologies – the term “5G” referring to a broader set of access technologies, both fixed wireless and mobile, that enable high-capacity, low-latency networks – offer a new set of opportunities help bridge the digital divide. Starry’s success in raising venture financing, building and deploying fixed wireless technology, and providing competitive choice to consumers is one clear and tangible example of how consumers are today directly benefiting from the policies adopted by the Commission. However, even with this forward progress, the Commission recognizes that there is much work still to do to enable this success,4 and we include herein some examples of areas that continue to be pressure points in the advancement of 5G technologies and services. II. Company Background & Technological Approach Starry is a Boston-based technology company that is using millimeter waves to re- imagine last-mile broadband access as an alternative to fixed-wireline broadband. Starry has developed and deployed proprietary pre-standard fixed 5G wireless technology that utilizes millimeter wave spectrum to connect consumers to affordable, high speed, gigabit-capable wireless broadband.5 Starry provides wireless last-mile connectivity at a fraction of the cost of fixed wireline providers, creating a scalable and competitive broadband alternative in markets that are often dominated by one or two players. To date, Starry has invested more than $163 million in technology research and development, network deployment, network service, and customer care and will invest additional significant financial resources over the next year. 4 Remarks of FCC Chairman Ajit Pai, Federalist Society 2018 National Lawyers Convention, “The current landscape of telecommunications law,” ( Nov.16, 2018), https://docs.fcc.gov/public/attachments/DOC-355136A1.pdf FCC 2018 Broadband Deployment Report: https://www.fcc.gov/reports-research/reports/broadband-progress- reports/2018-broadband-deployment-report. 5 Starry defines its technology as “pre-standard 5G” because Starry does not utilize 3GPP 5G NR radio technology in its base stations and more broadly, believes that for the average consumer the term “5G” represents a wider basket of access technologies that enable high-capacity, low-latency connections. Starry is not utilizing the 3GPP ecosystem, but rather is utilizing the more diverse 802.11 (WiFi) radio ecosystem governed by IEEE standards body for our baseband technology. 3 Starry was founded in late 2014 by a team of talented hardware, software, and RF engineers who set out to develop millimeter wave technology that could deliver reliable, gigabit-capable connections in dense and cluttered urban environments. Starry created and built a full-stack technology consisting of a network-node (“Starry Beam”), a home receiver (“Starry Point”) suitable for single family homes or multiple-dwellings (“MDUs”), and an in- home, touchscreen Wi-Fi access hub (“Starry Station”). In 2017, the FCC renewed Starry’s experimental market test authority licenses for the 37.0 to 38.6 GHz band in 22 markets. Starry has performed extensive tests to characterize the performance of these bands, testing weather, foliage, and seasonality impacts in both urban and suburban environments in multiple cities. Starry is now testing various business models for last-mile broadband in buildings and neighborhoods across several major U.S. cities, and is developing plans for extending its reach into less dense suburban areas. As required by the grant of this license, Starry submits this third progress report, which provides the Commission a significant update on our learnings over the past 30 months. Starry’s Technological Approach KEY TECHNOLOGY INNOVATIONS • Innovative approach to baseband radios in infrastructure: utilization of 802.11ac radios, transitioning to 802.11ax in 2019. • Capacity of 5 Gbps per beam sector with MU-MIMO (15-20 Gbps per site), improving to 10 Gbps per beam sector (40-50 Gbps per site), covering approximately 3 km in near-line-of-sight conditions and 1 km in non-direct-line- of-sight conditions. • Deployment of active phased array for consumer internet. • Hybrid multi-beamformed Rx & Tx. • Starry Beams cover 60, 90-degree or 120-degree sectors with an effective range of nearly 3 km, after taking into account rain fade, foliage and reflections. • Free space range in line-of-sight conditions is more than 10 km. Starry’s technical architecture includes three key components: Starry Beam, the network-node, which communicates using millimeter wave spectrum to Starry Point, the at- premise transceiver, which connects to Starry Station, the in-home WiFi hub. In addition to these network building blocks, Starry has also developed a low-cost relay system to add network coverage in extreme non-line-of-sight conditions. 4 Starry Beam utilizes an active phased array for Point-to-Multipoint delivery of last-mile fixed broadband to consumer premises. By taking the innovative approach of utilizing available 802.11ac and 802.11ax baseband technology in our infrastructure, which facilitates 4x4 and 8x8 Multi-User MIMO, Starry marries these two technological approaches to create a highly efficient, extremely low-cost, high-capacity internet delivery system using millimeter waves. This unique hybrid approach to beamforming is especially efficient and practical for millimeter waves due to the small sizes of the antennas. In addition, Starry’s full-stack technology approach provides it greater transparency and control over the performance and stability of the Starry internet service, from node to home, ensuring a better overall customer experience. In early 2019, Starry will begin to deploy its second-generation